Tallgrass Institute’s IRMA Primer and Position on Draft Indigenous Chapter Revisions
Tallgrass Institute has published a primer on the Responsible Mining Assurance (IRMA), discussing the Standard’s structure, how its audits work, and key improvements and critical gaps in proposed revisions to the Standard's chapter about Indigenous Peoples and FPIC.
Drawing from Tallgrass Instutute’s analysis, Position Statement on IRMA V2.0 Draft 2 – Chapter 2.2 (Indigenous Peoples & FPIC), improvements in the draft includes:
explicit expectations to not intatie contact for Indigenous Peoples living in voluntary isolation
separation of past harms from new approvals
separation of general public consultation and engagement with Indigenous Peoples unless Indigenous Peoples agree to combining
requirement to collaborate with affected Indigenous Peoples to develop and implement a grievance mechanism specific to them
funding for independent, Indigenous‑chosen advisors
scoring guardrail that prevents a high mark on the Indigenous item if the overall grievance system is weak
Recommendations to gaps identified in the analysis were:
Requirement for community‑led, neutrally facilitated process with the audit facilitator chosen by the Indigenous Peoples to confirm legitimate representatives and make completion of this process a prerequisite to concluding FPIC.
Clearer langauge for the grievance scoring rule, requiring in‑country, locally accessible intake, plus a gender‑responsive, language‑access plan co‑designed with Indigenous Peoples.
Not to grant partial credit unless operations are paused or limited in line with the Indigenous Peoples’ decision.
Making work pause mandatory whenever there is credible evidence of a breach of FPIC or new facts that could change the FPIC outcome with clear time limits for when information will be available.
To make it a clear, binding rule that consent is stage‑ and scope‑specific.
To co‑design disclosure and redaction rules with Indigenous Peoples and to keep promises and performance visible while protecting sensitive knowledge.
Clarification that customary rights is distinct from FPIC, reaffirming that binding FPIC in chapter 2.2 applies to Indigenous Peoples.
Requriemnt that mining sites notify buyers and lenders within a set time when FPIC status changes.